Tusen Takk
Privacy Policy
1 Controller
The controller within the meaning of the General Data Protection Regulation ("GDPR") is:
True Nordic UG (haftungsbeschränkt)
Registered office: Berlin
Business address:
Gasborn 23
52062 Aachen, Germany
Represented by managing director Constantin Hirt
Email: constantin@tusentakk.app
2 Scope
This Privacy Policy applies to the mobile application "Tusen Takk" (iOS, and potentially Android) and the website tusentakk.app.
3 What data we process
3.1 Account and profile data
During registration and use, we process the following data:
- Name (display name in the app);
- Email address;
- Password as a bcrypt hash (salt rounds: 10) — the plaintext password is never stored;
- Registration timestamp;
- PayPal.Me username (if stored by the User in their profile);
- Profile photo / avatar (if uploaded).
3.2 Transaction and activity data
- Sent and received Gift Tokens (gift type, amount in cents, status, timestamps);
- Occasion texts and notes optionally entered when sending;
- Selfies and captions uploaded for redemption;
- Approval/rejection decisions and timestamps;
- Chat entries (comments, reactions, photos) in the gift history;
- Points events ("Social Score"), weekly challenges, achievements, friendship connections;
- For unregistered recipients: their email address as a pending gift entry, until registration or for a maximum of 90 days.
3.3 Device and technical data
- Authentication token (JWT, validity 30 days, stored locally on the device);
- Push notification token (Expo Push Service), if the User has enabled push notifications;
- Server log data (timestamp, IP address, user agent, accessed endpoints) to ensure functionality and ward off attacks.
4 Purposes and legal bases for processing
| Purpose | Legal basis |
|---|---|
| Provision of the app, authentication and account management | Art. 6(1)(b) GDPR (performance of contract) |
| Processing of gift transactions including redemption and payout | Art. 6(1)(b) GDPR |
| Display of selfies to the Sender for approval | Art. 6(1)(b) GDPR as well as Art. 6(1)(a) GDPR (consent), see section 6 |
| Push notifications | Art. 6(1)(a) GDPR (consent) and Art. 6(1)(b) GDPR |
| Points, levels and leaderboard function | Art. 6(1)(b) GDPR |
| Server logs for IT security | Art. 6(1)(f) GDPR (legitimate interest) |
| Compliance with legal obligations (e.g. information and retention obligations) | Art. 6(1)(c) GDPR |
5 Recipients and processors
We share personal data with recipients only where this is necessary for the provision of the service or a legal obligation exists. The following processors and independent recipients are used:
- PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg — processing of payouts via PayPal.Me. Only the PayPal.Me username and the payout amount are transmitted.
- Expo (650 Industries, Inc.), USA — provision of the push notification service. Data transfer to the USA on the basis of EU Standard Contractual Clauses.
- Railway Corporation, USA — hosting and operation of the backend servers (Express); EU-West server location on Google Cloud infrastructure. An EU server location does not rule out possible third-country processing by the US provider.
- Google Cloud EMEA Ltd., Ireland — cloud infrastructure for backend hosting by Railway in the EU-West region.
- Functional Software, Inc. d/b/a Sentry, USA — error and performance monitoring using the selected EU data region in Frankfurt; possible third-country processing under the contractual arrangements and subject to Art. 44 et seq. GDPR. The EU data region concerns storage of error and performance data; certain account, organisation and support data may also be processed in the USA.
- Plus Five Five, Inc. (Resend), USA — sending transactional emails, in particular gift invitations and verification codes. Recipient addresses, message contents and technical sending and delivery data are processed.
- Apple Inc. — distribution of the app via the App Store; technical telemetry data is transmitted in accordance with Apple's guidelines.
Transfer of data to third countries outside the EU/EEA takes place only on the basis of appropriate safeguards pursuant to Art. 44 et seq. GDPR.
6 Selfie Proof & Photos
When redeeming a gift of thanks, the recipient may voluntarily take a selfie as proof. This photo is a central part of the Tusen Takk experience — it shows the gift giver the moment of thanks.
Data collected
A single photo, usually in JPEG format, deliberately captured and uploaded by the recipient. We perform no face recognition, biometric analysis, face mapping or automated image analysis. The photo is not identity verification — it is a human-readable moment of gratitude.
Use
In the app, the photo is shown to the sender of the associated gift and to the recipient themselves in their own transaction history. There is no public photo gallery. No automated analysis, no AI training and no advertising use take place.
Legal basis: Art. 6(1)(b) GDPR (execution of the user-initiated redemption process) as well as Art. 6(1)(a) GDPR (consent through deliberate upload).
Sharing with third parties
Photos are not automatically transmitted to advertising partners, analytics services or AI services. We do not use any face recognition technology. The hosting processors used for storage and operation process the data to provide the service.
Users may voluntarily export photos to services of their choice (e.g. Instagram or Messages) using the native iOS share function or the Instagram Story function. This is a user-directed action, not automatic sharing by Tusen Takk. Copies you export are subject to the privacy and deletion policies of the chosen services.
Storage
Photos are stored at Neon (managed PostgreSQL) and encrypted at rest with AES-256 under Neon's standard encryption. Access through the app requires authentication. No public photo URLs are provided.
Retention
The photo generally remains linked to the associated gift transaction so that you and your peer can revisit the moment. Image contents are removed when a redemption is rejected. An automated job additionally clears any remaining image contents of rejected selfies after 30 days. Account deletion follows the process described below.
Deletion
You can request deletion of your entire account through the app. A 30-day waiting period follows the deletion request. Once that period has elapsed, the automated cleanup job, which runs daily, removes redemption selfie image contents from the live database for all gifts where your account is the sender or recipient. The account is anonymised; shared transaction records are retained without these selfie image contents.
A function for deleting an individual transaction selfie is not currently available. To request deletion of an individual photo or withdraw your consent, contact constantin@tusentakk.app.
Your rights
You can view your photo in the app and export it using the data-export feature in your profile. For other privacy requests, email us at constantin@tusentakk.app. Your general privacy rights are described in Section 8.
7 Storage periods
- Account and profile data: following an account deletion request, cleanup and anonymisation by the automated job after the 30-day waiting period (see Section 6).
- Transaction data: shared transaction records are retained upon account deletion; the associated account is anonymised and selfie image contents are removed as described in Section 6. Statutory retention periods remain unaffected.
- Redemption selfies: retention and removal as described in Section 6; there is no general automatic deletion 30 days after confirmation or upload. Account cleanup also removes photo contents uploaded by the deleted account in chat and timeline entries.
- Pending gifts (email addresses of unregistered recipients): automatic deletion after 90 days without claim.
- Server logs: max. 30 days.
- Push tokens: until withdrawal of push consent or account deletion.
8 Your rights
You have the right at any time to:
- Access to data stored about you (Art. 15 GDPR);
- Rectification of inaccurate data (Art. 16 GDPR);
- Erasure (Art. 17 GDPR);
- Restriction of processing (Art. 18 GDPR);
- Data portability (Art. 20 GDPR);
- Objection to processing based on Art. 6(1)(f) GDPR (Art. 21 GDPR);
- Withdrawal of consent with future effect (Art. 7(3) GDPR);
- Lodge a complaint with a supervisory authority (Art. 77 GDPR).
The supervisory authority responsible for the company is the Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI, Berlin Commissioner for Data Protection and Freedom of Information), Alt-Moabit 59-61, 10555 Berlin, Germany. Your right to lodge a complaint with another competent supervisory authority under Art. 77 GDPR remains unaffected.
To exercise your rights, a simple message to constantin@tusentakk.app or use of the "Delete account" function in the app (Profile → Settings) is sufficient.
9 Security
- All data transmission exclusively encrypted via HTTPS/TLS;
- Passwords are hashed with bcrypt and not stored in plaintext;
- Authentication via JWT tokens with limited validity;
- Database access is only possible for authorised services and persons;
- Rate limiting on sensitive endpoints (login, signup, coin send, avatar upload);
- Regular updates of components in use.
10 Automated decisions and profiling
No exclusively automated decision-making within the meaning of Art. 22 GDPR takes place. The approval of a selfie is always carried out manually by the Sender. Points are awarded according to fixed rules and do not lead to legal or comparably significant effects.
11 Changes to this Privacy Policy
We reserve the right to update this Privacy Policy when app functions change or the legal situation requires it. Material changes will be communicated via the app or by email.
12 Data protection contact
For questions about data protection or to exercise your rights, please contact us at:
True Nordic UG (haftungsbeschränkt) — Data Protection
Gasborn 23
52062 Aachen
Germany
Represented by managing director Constantin Hirt
Email: constantin@tusentakk.app